Certification of Multi-Ingredient Products when Imported Ingredients are Included in the Calculation of Organic Content
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Date: October 25, 2010
Canadian Food Inspection Agency
Canada Organic Office
1400 Merivale Road
Ottawa, Ontario, Canada, K1A 0Y9
1.0 Purpose and Scope
This directive outlines the requirements for certification of multi-ingredient products when imported ingredients are included in the calculation of organic content.
- The Organic Products Regulations (OPR)
- The US-Canada Organic equivalence arrangement
The percentage of organic products contained in a multi-ingredient product shall be determined in accordance with CAN/CGSB 32.310. The OPR define an organic product as an agricultural product that has been certified as organic in accordance with the OPR or that has been certified as organic under section 27 of the OPR.
Pursuant to section 27 of the OPR, on June 17, 2009, Canada and the US entered into an arrangement recognizing the national organic systems as equivalent.
Organic products imported into Canada that have been certified under the US system are subject to the following conditions:
- Agricultural products produced with the use of sodium nitrate shall not be sold or marketed as organic in Canada.
- Agricultural products produced by hydroponic or aeroponic production methods shall not be sold or marketed as organic in Canada.
- Agricultural products derived from animals must be produced according to livestock stocking rates as set out in CAN/CGSB-32.310-2006 (amended October 2008).
4.0 Roles and Responsibilities
CFIA - accredited Certification Bodies (CB) will be responsible for the application of this directive. They are responsible for ensuring that multi-ingredient products, when imported ingredients are included in the calculation of organic content, comply with the OPR.
CFIA designated Conformity Verification Body (CVB) will be responsible for monitoring the certification activities of the CFIA accredited Certification Bodies (CBs).
When imported ingredients are included in the calculation of organic content, CBs must verify that the imported ingredient complies with the OPR.
- Ingredients certified to the Canada Organic Regime (COR) by a CFIA accredited CB.
- Ingredients certified under the US-Canada Organic equivalence arrangement.
CB must verify records to ensure imported ingredient was certified to CAN/CGSB-32.310 or to the terms of the US-Canada Organic equivalence arrangement. Certification to foreign standard does not meet the requirements of the OPR.
Conformity Verification Body
CVB shall review the verification procedures and records during each onsite audit it performs at the CB office. CVB shall also ensure that the documents provided to the operators by the CB contain the appropriate terms, as described in paragraph 6.0 of this directive.
6.0 Documentation requirements
As per Section 28 of the OPR, products imported into Canada must be accompanied by document attesting that they are "certified in accordance with CAN/CGSB 32.310" or are "certified to the terms of the US-Canada Organic equivalency agreement".
Exported products intended for sale in the United States must be certified to the terms of the US-Canada Organic equivalence arrangement and must be accompanied by document attesting that they are "certified to the terms of the US-Canada Organic equivalence arrangement".
The documentation on which attestation could be added may be in the form of a transaction certificate, certificate addendum or any other affirmative attestation issued by the CB. The attestation must be issued by the CB who verified the product. Copies of these documents must be maintained by the accredited CB, exporter and importer for review by the National Organic Program (NOP), CFIA designated CVBs and/or CFIA officials.
Inquiries concerning this directive should be addressed to the Canada Organic Office.
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